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L8r BOI?
To:Brew Readers
CFO Brew // Morning Brew // Update
Beneficial ownership reporting is in limbo but not gone yet.

Hello, and welcome to Tuesday. Is it just us, or does it feel like we might be in for a lot of busy news days for the foreseeable future?

In this issue:

Gone for good?

Bitter pill

Roll of the DISE

Drew Adamek, Graison Dangor, Alex Zank, Courtney Vien

COMPLIANCE

BOI Fincen compliance

Pm Images/Getty Images

More than a year after the Treasury Department introduced its form for companies to report who owns and controls them, legal challenges mean it’s still unclear whether Beneficial Ownership Information (BOI) will end up being required. But experts told CFO Brew that companies are still better off gathering the information in case the government is able to fend off challenges to the law that requires it.

“You should be collecting the information that you need to make a filing, but holding it until the courts provide more clarity,” according to Matthew Bisanz, a partner at Mayer Brown who leads its task force on the Corporate Transparency Act (CTA) and has worked with, by his estimation, 150 clients who had questions about complying with the act over the last year.

The simplicity of the BOI form doesn’t capture how much behind-the-scenes work may be needed to fill it out, according to Christopher Kula, a partner at Dentons who advises mostly private funds on how to comply with the CTA. It can take weeks to look at all the companies a business owns, see whether the law applies, and map out the beneficial owners of each. For example, asset management clients “may have vehicles with hundreds of subsidiaries” that have to report, Bisanz said.

While the new Trump administration could just drop the government’s defense of the CTA, Bisanz doesn’t think that will happen, nor does he think it will spend time undermining the law with administrative actions.

“They probably have higher priorities elsewhere,” he said.

For more on what to do about beneficial ownership reporting, click here.GD

Presented By Eftsure

COST MANAGEMENT

Healthcare costs

Malte Mueller/Getty Images

Would you, the cost-minded CFO, be surprised to hear that healthcare benefit costs rose last year and are expected to increase at an even greater clip this year? No? We aren’t either, TBH.

Employer-sponsored health plan costs rose 4.5% in 2024 to an average per-employee cost of $16,501, marking “a second year of elevated cost growth,” according to the latest Mercer survey of organizations with at least 50 employees.

Respondents said they expect health benefit costs to increase by 5.8% in 2025. Without making changes to health plans, respondents said costs would instead rise by nearly 8%.

Costs have tracked above the overall rate of inflation going back to at least 2013, the survey report shows, with 2022 being the sole exception.

Highly medicated. There’s hope that health costs will decrease now that overall inflation has cooled, though other factors remain that contribute to the upward climb, Beth Umland, research director in Mercer’s health and benefits business, said in a recent episode of Mercer’s The Beneficial Workplace podcast.

Click here for more on rising employer healthcare costs.AZ

REPORTING

FASB DISE regulation disclosure

Yauhen Akulich/Getty Images

All public companies need to comply with Accounting Standards Update No. 2024-03—popularly known as the Disaggregation of Income Statement Expenses, or DISE—on their annual financial statements for reporting periods starting after December 15, 2026, the FASB stated in a recent update.

The standard was released in November 2024. Since that time, FASB has realized its wording may have been confusing to some companies. (An accounting standard that’s difficult to interpret? We’re shocked!) In particular, companies that didn’t use a calendar year-end thought they might have needed to comply with DISE in their first interim or quarterly statements following December 15, 2026. But that wasn’t FASB’s intent.

In its update, FASB noted that all public companies, regardless of the calendar they use, must comply with DISE on annual statements for reporting periods starting after December 15, 2026, and on interim statements for reporting periods starting after December 15, 2027.

That news will likely come as a relief to some companies, as DISE compliance is, in the words of FASB Chair Rich Jones, a “significant lift.” The standard requires companies to disclose additional information on certain expenses such as employee compensation, inventory purchases, depreciation, and amortization of intangible assets.

Keep reading here.CV

Together With Sage

MARKET FORCES

market forces chart

Francis Scialabba

Today’s top finance reads.

Stat: Almost 10%. That’s how much Champagne shipments from France have fallen as inflation and a general global grumpiness sink the desire to celebrate. (CNN Business)

Quote: “There is no wealth creation…And after an initial spike, the price eventually crashes and the last buyers lose everything.”—investor Balaji Srinivasan, on the $TRUMP memecoin, which at one point hit a value of $10 billion this weekend before losing over half its value. (The Atlantic)

Read: A Big Four firm moves into law? (Wall Street Journal)

Fraud finder: Eftsure’s Cybersecurity Guide for CFOs 2025 helps business leaders defend against scams by outlining the latest AI-enabled fraud tactics and how they work. See how CFOs can lead anti-cybercrime strategies.*

*A message from our sponsor.

JOBS

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